Non-reporting of specified domestic transactions U/s 92BA with related parties

HDFC Bank Ltd. Vs ACIT (Bombay High Court) Conclusion: Transaction of purchase of loan from HDFC ltd. would not cover within the meaning of Specified Domestic Transactions (SDTs) as the shareholding of HDFC Ltd. of 16.39% could not be clubbed with the shareholding of the HDFC Investments Ltd. of 6.25% to cross the threshold limit of substantial interest of 20%. Also, payment by assessee to HBL Global for rendering services would not fall under SDT as assessee was not directly beneficial owner of the shares of HBD Global.  Further, transaction of payment of interest by assessee to HDB Welfare ...